Non‑EU companies that relocate their headquarters to Italy may benefit from a 50% tax reduction for IRES and IRAP for 6 years (reshoring), provided that the activity has not been carried out in Italy during the previous 24 months. The incentive is subject to EU authorization and may be revoked if the business is moved abroad again within 5–10 years.


• **50% Tax Reduction:** 50% of business income produced in Italy does not contribute to the IRES (corporate income tax) and IRAP (regional production tax) taxable base. The benefit applies for the tax year in which the relocation occurs and for the following 5 years (total 6 years).
• **Eligible Subjects:** Companies and self‑employed workers (in associated form) transferring their activity from countries outside the EU or the European Economic Area (EEA).
• **Conditions:**
• **Anti‑Avoidance Clause:** If the activity is transferred outside the EU within 5 years (or 10 years for large enterprises) after the benefit ends, the incentive is revoked. Possible additional incentives for investments in SEZ areas, coordinated with the reshoring regime.
• Article 1, paragraphs 438–443, of Law 30 December 2025, no. 199, extends the tax credit established by Art. 16 of Decree‑Law 19 September 2023, no. 124, in favor of companies acquiring capital goods from 1 January 2026 to 31 December 2028, destined for existing or newly established production facilities located in the Southern Italy Special Economic Zone – the Single SEZ (“ZES unica”). This includes assisted areas in Basilicata, Calabria, Campania, Molise, Puglia, Sardinia, Sicily (eligible under Art. 107(3)(a) TFEU), and Marche, Umbria, Abruzzo (eligible under Art. 107(3)(c) TFEU), as defined by the Regional Aid Map 2022–2027.
• Article 1, paragraphs 438–443, defines access procedures, criteria, and methods for applying and using the tax credit, as well as related controls, ensuring compliance with the total expenditure limit of €2.3 billion for 2026.
• The credit, usable exclusively as a tax offset under Art. 17 of Legislative Decree 9 July 1997, no. 241, is granted in compliance with the limits and conditions of EU Regulation 651/2014 (“GBER Regulation”) and is cumulative with de minimis aid and other State aid.
• For 2026, the credit is calculated based on investments made from 1 January to 31 December 2026, with a maximum limit of €100 million per investment project. Projects with a total cost below €200,000 are not eligible.
• Under Art. 7, paragraph 14, of the implementing decree (Minister for European Affairs, the South, Cohesion Policies and PNRR, 17 May 2024), eligible expenses and their correspondence with the company’s accounting documentation must be certified by a professional registered in Section A of the Register of Statutory Auditors under Art. 8 of Legislative Decree 27 January 2010, no. 39.